Document kgNjK9YX3KDDEqonkD9KVEVE
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Federal: Register / Vol. 51. No. 119 / Friday, June 20, 1980 / Rules and Regulations
to 0.57 f/cc with a geometric.mean value
of 0.09 f/cc [Exhibit 84-474, Table 3.10).
OSHA as.sumes'that smaller jobs would
be associated with such lower TWAs
(due to the shorter duration of
exposure). In addition, "glove bags" are
available for certain types of jobs. In 15
area samples collected during the
removal of asbestos from steam pipes
while using glove bags [Exhibit 84-474.
Table A-2[, TWA concentrations ranged
from below detectable (less than 0.1 f/
cc) to 0.02 f/cc. These data demonstrate
that glove bags can reduce airborne
fiber concentrations to below the 0.2 f/
cc PEL.
Encapsulants are still being used in
many asbestos abatement projects.
Encapsulants are water-soluble latex
products that are sprayed on to asbestos
materials to bind and prevent the
release of asbestos fibers. An
encapsulant may either be a bridge,
which forms a film over the surface of
the insulation material, or a penetrant,
which soaks at least partially through
the fiber matrix. By its nature,
encapsulation, when applied by an
experienced professional, does not -
normally involve high fiber release. In
personal samples collected by Clayton
Environmental during the application of
both bridging and penetrating
encapsulants. TWA concentrations,
however, ranged from 0.03 f/cc to 0.28 f/
cc, with a geometric mean of 0.17 f/cc. `
Thus, with the majority of samples
below 0.2 f/cc, OSHA believes that it is
generally feasible, for.this sector to .
comply with the 0.2 f/cc PEL during
encapsulation work, although
respirators may be needed on some
projects.
Renovotion/RemodeUng ofExisting
Structures. Asbestos has been used
widely in construction until the mid-
1970s when certain.applications were
curtailed by the Environmental
Protection Agency (EPA). As a result,
substantial amounts of asbestos .
materials are present in numerous
buildings that were constructed in
earlier years.
In addition to the uses in new.
construction described above, materials
containing asbestos are used for pipe
and boiler insulation, fireproofing,
drywall tape and speckling, and
acoustical plasters. Consequently, such
materials are present in office buildings,
schools, hospitals, residential buildings,
industrial facilities, power plants, etc.
thatwere built in earlier years.
In renovation projects, workers
indirectly involved with asbestos
products may be exposed inadvertently
by disturbing these materials [Exhibit
207)..For example, in multistory
buildings where beams and/or decking
are covered with asbestos fireproofing, the adjustment of HVAC equipment
electricians, pipefitters, telephone
above suspended ceilings.
installers, or workers who repair heating TWA exposures ranging from 0.02 f/
ventilation and air-conditioners may be cc to 1.4 f/cc have been measured in
exposed to appreciable concentrations personal samples collected during the
of asbestos fibers when working above removal of drop ceiling tiles. In data
suspended ceilings. This exposure may reported by Paik and coworkers [Exhibit'
result from direct contact with the
207J, the average concentrations during
fireproofing, or from the disturbance of routine maintenance activities ranged
settled fibers from various surfaces
from 0.9 f/cc to 1.4 f/cc.
above the ceiling (i.e., existing pipe, ductwork, or drop ceiling tiles).
In personal samples collected in office buildings and schools, [Exhibit 84-474, p. 3.311 Clayton Environmental Consultants measured TWA exposures ranging from 0.02 f/cc to 1.4.f/cc, with a geometric mean of 0.14 f/cc, while workers were removing drop ceiling tiles
front the ceiling tract. The results of the samples collected in the breathing zones of electricians, pipefitters, and heating,
ventilation, and air-conditioning (HVAC) workers indicated geometric mean TWA concentrations of 0.11 f/cc, 0.12 f/cc, and 0.14 f/cc, respectively |Exhibit 84-474, Table A-12J. The highest value measured was 2.8 f/cc for an HVAC worker. In each case, wet methods were employed for any direct contact with asbestos material, and HEPA vacuums were used for clean-up. These values are consistent with OSHA inspection data [Exhibit 84-474. Table A-llj.
A variety of other activities may also involve the disturbance of asbestos materials and the subsequent exposure of renovation workers. For example, carpenters and drywallers may Install new walls which, if attached to beams covered with fireproofing; may result in exposure. The results of samples collected by Clayton Environmental Consultants, Inc., indicate geometric
mean TWA concentrations of 0.16 f/cc for carpenters and 0.41 f/cc fordrywallers. Personal samples taken by the Argonne National Laboratory during similar activities showed TWA concentrations ranging from 0.35 f/cc to 0.87 f/cc using wet methods and HEPA vacuums [Exhibit 84-474). '
OSHA has determined that -
In samples collected by Clayton Environmental during the inspection and repair of HVAC equipment near asbestos insulation materials, TWA concentrations ranged from 0.04 f/cc to 0.9 f/cc, with a geometric mean of 0.21 f/ cc (Exhibit 308, Table A-14). Results consistent with these findings were also reported by Argonne National
Laboratory during maintenance .
activities where wet handling was used, when possible, and where HEPA vacuums were used [Exhibit 298).
These data demonstrate a potential for exposure of maintenance personnel
to concentrations exceeding 0.5 f/cc. With the exception of wet handling, which is feasible in only very limited situations due to problems such as electrical wiring, and the use of HEPA vacuums for the clean-up of any debris generated during maintenance activities, OSHA believes that there does not appear to be any feasible engineering controls or work practices available to reduce these potential exposures to levels below the 0.2 f/cc PEL and that respirators will.be required to comply with the 0.2 f/cc PEL.
Demolition. Demolition of all or part of a building or industrial facility that
contains asbestos would also be likely, to cause a disturbance of asbestos
materials. Under current EPA regulations (40
CFR Part 61, Subpart M, National Emission Standard for Asbestos), demolition is defined as the "wrecking to taking out (SIC) of any loadsupportingstructural member of a facility together with any related handling operations." EPA requires that
friable asbestos materials be removed
engineering controls (such as negativepressure enclosures and vacuums) are generally effective in limiting exposures
from buildings or industrial facilities prior to wrecking or dismantling the structures. Presuming compliance with
after asbestos containing materials have the EPA regulation, the only potential
been disturbed, but that workers who
for exposure would beduring the
actively disturb these materials will
removal of such materials before
probably require respiratory protection demolition. The feasibility of
to comply with the 0.2 f/cc.PEL.
compliance with the 0.2 f/cc PEL for
Routine Facility Maintenance.
asbestos removal was discussed
Routine maintenance and repair
previously. The demolition project at the
activities may also involve the
National Press Building in Washington,
disturbance of asbestos materials and
D.C., further illustrates this feasibility.
products, as described in the industry
During this project, work practices were
profile. Such activities include the repair so effective in limiting exposure levels
of leaking steam pipes in buildings and that asbestos levels were higher outside
O
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